FL-921 – Improperly Bolted Seats – 2020-2023 Thomas Built Buses Saf-T-Liner EFX School Buses

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Defect Information Report (Section 573.6) FL-921 Date of Submission: March 11, 2022 Manufacturer: Daimler Trucks North America LLC P.O. BOX 3849 Portland, Oregon 97208 Type of Report: X Safety Defect X Non-Compliance Vehicle Information Model Yr. Start: 2020 Model Yr. End: 2023 Make: Thomas Built Buses Model: Saf-T-Liner EFX Production Dates: Begin: 6/6/2019 End: 11/30/2021 Type: School Bus Descriptive Information: Saf-T-Liner EFX school buses with a potential interference of certain chassis cross-member bolts and certain passenger seat floor mounting bolts Number potentially involved: 539 vehicles Estimated percentage of involve with defect: 75% Defect / Noncompliance Description For this Defect/Noncompliance: Describe the defect or noncompliance: On the affected EFX school buses there may be certain passenger seats that have a mounting bolt that may contact a chassis cross-member bolt. Over time, the passenger seat bolt may fatigue from vibration and side loading. A broken seat mounting bolt may impact the ability of the seat to meet the seat and belt requirements of FMVSS 210 and/or FMVSS 222. If a noncompliance, provide the applicable FMVSS: FMVSS 210 and FMVSS 222 Describe the safety risk: A broken seat bolt may impact the ability of the seat to meet the requirements of FMVSS 210 and or FMVSS 222. This may increase the risk of injury to the occupants in the event of a crash. Identify any warning which can precede or occur: NA If applicable, identify the manufacture of the defective or noncompliant component: TBB 170727 – BOLT HEX FLANGE 7/16-14X2.0 SAE GRADE 8. Involved Components Component Name: Fastener Component Description: BOLT HEX FLANGE 7/16-14X2.0 SAE GRADE 8 Component Part Number: 170727 Chronology of Defect / Noncompliance Determination Provide the chronology of events leading up to the defect decision or test data for the noncompliance decision. In January 2022 DTNA received report from a customer of broken passenger seat floor mounting bolts. Thomas Built Buses (TBB) immediately initiated a quality containment on all EFX buses with similar configurations and began an investigation to determine the scope and potential consequences of the issue. TBB promptly began inspecting EFX buses on property and identified a certain cross-member location that may , under certain conditions of tolerance stack-up, lead to interference between a seat mounting bolt and a cross-member bolt. TBB then promptly developed a predictive model, and validated it with inspection of EFX buses on property,that could compare seat and cross-member locations to identify suspect buses. At the same time, TBB reviewed FMVSS compliance testing data to determine if a broken bolt could affect the compliance of the seats. In March 2022 as soon as DTNA had sufficient information from its investigation, DTNA decided to conduct a voluntary non-compliance and safety recall on certain EFX school buses with a configuration that may allow a passenger seat mounting bolt and a chassis cross member bolt align and make contact. Identify the Remedy Describe the defect/noncompliance remedy program, including the manufacture’s plan for reimbursement. Spacer will be added between the frame rails and body floor in the affected area on the affected buses to provide proper clearance between the passenger seat mounting bolt and a chassis cross member bolt. Repairs will be performed by Daimler Truck North America authorized service facilities. Details of the reimbursement plan will be included in the owner’s notification letter. Identify the Recall Schedule Describe the recall schedule for notifications: Customer notification will be made by first class mail using Daimler Truck North America records to determine the customers affected. Planned Dealer Notification Begin Date: 05/09/2022 Planned Dealer Notification End Date: 05/09/2022 Planned Owner Notification Begin Date: 05/09/2022 Planned Owner Notification End Date: 05/09/2022 Manufacture’s identification code for this recall (if applicable): FL-921 DTNA Representative; Tiffani Torgeson Manager, Compliance and Regulatory Affairs

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Daimler Trucks North America LLC June 2022 FL921A NHTSA #22V-153 REVISED NOTICE IMPORTANT SAFETY RECALL See enclosed VIN list Subject: TBB EFX Seat Bolts REVISION: The model description and problem statement have been revised. This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act. Daimler Trucks North America LLC (DTNA), on behalf of its wholly owned subsidiary, Thomas Built Buses, has decided that certain Model Year 2020-2023 Saf-T-Liner EFX school buses manufactured June 6, 2019, through November 30, 2021 fail to conform to Federal Motor Vehicle Safety Standards No. 210, “Seat Belt Assembly Anchorage” and No. 222, “School Bus Passenger Seating and Crash Protection.” On the affected EFX school buses, certain passenger seats have a mounting bolt that may contact a chassis cross-member bolt which can cause fatigue from vibration and side loading. A broken seat mounting bolt may not properly restrain an occupant in a crash which can increase their risk of injury. Spacers will be added between the frame rail and body floor in the affected area of the bus to provide proper clearance between the passenger seat mounting bolt and the chassis cross member bolt. Repairs will be performed by Daimler Trucks North America authorized service facilities. Please contact an authorized Daimler Trucks North America dealer to arrange to have the Recall performed and to ensure that parts are available at the dealership. To locate an authorized dealer, search online at Daimler-TrucksNorthAmerica.com/Contact-us. Scroll down to “Locate a Dealer” and select the appropriate brand. The Recall will take approximately five hours and will be performed at no charge to you. You may also confirm your vehicle’s involvement in this recall at this URL: https://dtna-dlrinfo.prd.freightliner.com:48518/VinLookup/vin-module/getVinLookupPage. You may be liable for any progressive damage that results from your failure to complete the Recall within a reasonable time after receiving notification. If you do not own the vehicle that corresponds to the identification number(s) which appears on the Recall Notification, please return the notification to the Warranty Campaigns Department with any information you can furnish that will assist us in locating the present owner. If you have leased this vehicle, Federal law requires that you forward this notice to the lessee within 10 days. If you are a subsequent stage manufacturer, Federal law requires that you forward this notice to your distributors and retail outlets within five working days. If you have paid to have this recall condition corrected prior to this notice, you may be eligible to receive reimbursement. Please see the reverse side of this notice for details. If you have questions about this Recall, please contact the Warranty Campaigns Department at (800) 547-0712, 7:00 a.m. to 4:00 p.m. Pacific Time, Monday through Friday, e-mail address [email protected]. For other concerns, you may contact the Customer Assistance Center at (800) 385-4357. If you are not able to have the defect remedied without charge and within a reasonable time, you may wish to submit a complaint to the Administrator, National Highway Traffic Safety Administration, 1200 New Jersey Avenue SE, Washington, DC 20590; or call the Vehicle Safety Hotline at (888) 327-4236 (TTY: 800-424-9153); or go to http://www.safercar.gov. We regret any inconvenience this action may cause but feel certain you understand our interest in motor vehicle safety. Daimler Trucks North America LLC Warranty Campaigns Department P.O. Box 4090 Portland, OR 97208-4090 800.547.0712 Phone WARRANTY CAMPAIGNS DEPARTMENT Enclosure Daimler Trucks North America LLC Reimbursement to Customers for Repairs Performed Prior to Recall If you have already paid to have this recall condition corrected you may be eligible to receive reimbursement. Requests for reimbursement may include parts and labor. Reimbursement may be limited to the amount the repair would have cost if completed by an authorized Daimler Trucks North America LLC dealer. The following documentation must be presented to your dealer for consideration for reimbursement. Please provide original or clear copies of all receipts, invoices, and repair orders that show: • The name and address of the person who paid for the repair. • The Vehicle Identification Number (VIN) of the vehicle that was repaired. • What problem occurred, what repair was done, when the repair was done. • Who repaired the vehicle. • The total cost of the repair expense that is being claimed. • Proof of payment for the repair (such as the front and back of a cancelled check or a credit card receipt). Reimbursement will be made by check from your Daimler Trucks North America LLC dealer. Please speak with your Daimler Trucks North America LLC authorized dealer concerning this matter Daimler Trucks North America LLC Warranty Campaigns Department P.O. Box 4090 Portland, OR 97208-4090 800.547.0712 Phone

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Subject: Thomas Built Buses EFX Seat Bolts Models Affected: Specific model years 2020-2023 Thomas Built Saf-T-Liner EFX school buses manufactured June 6, 2019, through November 30, 2021. General Information Daimler Truck North America LLC (DTNA), on behalf of its wholly owned subsidiary, Thomas Built Buses (TBB) has decided that a defect that relates to motor vehicle safety exists on the vehicles mentioned above. On the affected EFX school buses, certain passenger seats have a mounting bolt that may contact a chassis cross-member bolt which can cause fatigue from vibration and side loading. A broken seat mounting bolt may impact the ability of the seat to meet the seat and belt requirements of FMVSS 210 and/or FMVSS 222. Spacers will be added between the frame rail and body floor in the affected area of the bus to provide proper clearance between the passenger seat mounting bolt and the chassis cross member bolt. Repairs will be performed by Daimler Truck North America authorized service facilities. There are approximately 539 vehicles involved in this campaign. Additional Repairs Dealers must complete all outstanding Recall and Field Service campaigns prior to the sale or delivery of a vehicle. A Dealer will be liable for any progressive damage that results from its failure to complete campaigns before sale or delivery of a vehicle. Owners may be liable for any progressive damage that results from failure to complete campaigns within a reasonable time after receiving notification. Work Instructions Please refer to the attached work instructions. Replacement Parts Replacement parts are now available and can be obtained by ordering the part number(s) listed below from your facing Parts Distribution Center. If our records show your dealership has ordered any vehicle(s) involved in campaign number FL921, a list of the customers and vehicle identification numbers will be available on DTNAConnect. Please refer to this list when ordering parts for this recall. Table 1 – Replacement Parts for FL921 Daimler Truck North America LLC Recall Campaign May 2022 FL921A NHTSA #22V-153 Page 1 Campaign Number Part Description Part Number Qty. FL921A SHIM BASE PLATE, ASSEMBLY TBB 235016 2 ea BODY CLIP, J-HOOK TBB 185130 8 ea ROD, HOOK, 7/16 – 14 TBB 232967 4 ea WASHER, FLAT, . 500 ID, I . 630 OD TBB 173796 6 ea LOCKNUT 7/16- 14 PREVAILING TBB 29940038 4 ea SHIM BRACKET TBB 235017 2 ea WASHER, FLAT, .531 ID, 1.062 OD 23-09114-003 2 ea BODY CLIP, J-HOOK, WIDE OPENING TBB 235162 2 ea SEAT MOUNTING BOLT, GRADE 8, 4.00 INCH TBB 216585 2 ea SEAT MOUNTING BOLT, GRADE 8, 4.50 INCH TBB 216586 2 ea FLANGE NUT, 7/16-14 GRADE 8 TBB 233162 2 ea Table 1 Removed Parts U.S. and Canadian Dealers, please follow Warranty Failed Parts Tracking shipping instructions for the disposition of all removed parts. Export distributors, please destroy removed parts unless otherwise advised. Labor Allowance Table 2 – Labor Allowance Campaign Number Procedure Time Allowed (hours) SRT Code Corrective Action FL921A INSTALL BODY SHIMS FOR SEAT BOLT CLEARANCE 4.5 996-R142A 12-Repair Recall/Campaign Table 2 Claims for Credit You will be reimbursed for your parts, labor, and handling (landed cost for Export Distributors) by submitting your claim through the Warranty system within 30 days of completing this campaign. Please reference the following information in OWL: • Claim type is Recall Campaign. • In the Campaign field, enter the campaign number and appropriate condition code (FL921-A). • In the Primary Failed Part Number field, enter 25-FL921-000. • In the Parts field, enter the appropriate part number(s) as shown in the Replacement Parts Table. • In the Labor field, first enter the appropriate SRT from the Labor Allowance Table. Administrative time will be included automatically as SRT 939-6010A for 0.3 hours. • The VMRS Component Code is F99-999-005 and the Cause Code is A1 – Campaign. • U.S. and Canada — Reimbursement for Prior Repairs. When a customer asks about reimbursement, please do the following: • Accept the documentation of the previous repair. • Make a brief check of the customer’s paperwork to see if the repair may be eligible for reimbursement. (See the “Copy of Owner Letter” section of this bulletin for reimbursement guidelines.) • Submit an OWL Recall Pre-Approval Request for a decision. • Include the approved amount on your claim in the Other Charges section. Daimler Truck North America LLC Recall Campaign May 2022 FL921A NHTSA #22V-153 Page 2 • Attach the documentation to the pre-approval request. • If approved, submit a based on claim for the pre-approval. • Reimburse the customer the appropriate amount. IMPORTANT: OWL must be viewed prior to performing the recall to ensure the vehicle is involved and the campaign has not been previously completed. U.S. and Canadian dealers, contact the Warranty Campaigns Department via Web inquiry at DTNAConnect.com/WSC, if you have any questions or need additional information. Export distributors, submit a Web inquiry or contact your International Service Manager. U.S. and Canadian Dealers: To return excess kit inventory related to this campaign, U.S. dealers must submit a Parts Authorization Return (PAR) to the Memphis PDC. Canadian dealers must submit a PAR to their facing PDC. All kits must be in resalable condition. PAR requests must include the original purchase invoice number. Export Distributors: Excess inventory is not returnable. The letter notifying U.S. and Canadian vehicle owners is included for your reference. Please note that the National Traffic and Motor Vehicle Safety Act, as amended (Title 49, United States Code, Chapter 301), requires the owner’s vehicle(s) be corrected within a reasonable time after parts are available to you. The Act states that failure to repair a vehicle within 60 days after tender for repair shall be prima facie evidence of an unreasonable time. However, circumstances of a particular situation may reduce the 60 day period. Failure to repair a vehicle within a reasonable time can result in either the obligation to (a) replace the vehicle with an identical or reasonably equivalent vehicle, without charge, or (b) refund the purchase price in full, less a reasonable allowance for depreciation. The Act further prohibits dealers from selling a vehicle unless all outstanding recalls are performed. Any lessor is required to send a copy of the recall notification to the lessee within 10 days. Any subsequent stage manufacturer is required to forward this notice to its distributors and retail outlets within five working days. Daimler Truck North America LLC Recall Campaign May 2022 FL921A NHTSA #22V-153 Page 3 Copy of Notice to Owners Subject: Thomas Built Buses EFX Seat Bolts For the Notice to U.S. Customers: This notice is sent to you in accordance with the National Traffic and Motor Vehicle Safety Act. Daimler Truck North America LLC (DTNA), on behalf of its wholly owned subsidiary, Thomas Built Buses, has decided that a defect that relates to motor vehicle safety exists on specific model years 2020-2023 Thomas Built Saf-T-Liner EFX school buses manufactured June 6, 2019, through November 30, 2021. On the affected EFX school buses, certain passenger seats have a mounting bolt that may contact a chassis cross-member bolt which can cause fatigue from vibration and side loading. A broken seat mounting bolt may impact the ability of the seat to meet the seat and belt requirements of FMVSS 210 and/or FMVSS 222. Spacers will be added between the frame rail and body floor in the affected area of the bus to provide proper clearance between the passenger seat mounting bolt and the chassis cross member bolt. Repairs will be performed by Daimler Truck North America authorized service facilities. Please contact an authorized Daimler Truck North America dealer to arrange to have the Recall performed and to ensure that parts are available at the dealership. The Recall will take approximately five hours and will be performed at no charge to you. To locate an authorized dealer, search online at https:// northamerica.daimlertruck.com/contact-us/. Scroll down to “Locate a Dealer,” and select the appropriate brand. You may also confirm your vehicle’s involvement in this recall at this URL: https:// dtna-dlrinfo.prd.freightliner.com:48518/VinLookup/vin-module/getVinLookupPage. You may be liable for any progressive damage that results from your failure to complete the Recall within a reasonable time after receiving notification. If you do not own the vehicle that corresponds to the identification number(s) which appears on the Recall Notification, please return the notification to the Warranty Campaigns Department in the postage-paid envelope with any information you can furnish that will assist us in locating the present owner. If you have leased this vehicle, Federal law requires that you forward this notice to the lessee within 10 days. If you are a subsequent stage manufacturer, Federal law requires that you forward this notice to your distributors and retail outlets within five working days. If you have paid to have this recall condition corrected prior to this notice, you may be eligible to receive reimbursement. Please see the reverse side of this notice for details. If you have questions about this Recall, please contact the Warranty Campaigns Department at (800) 547-0712, 7:00 a.m. to 4:00 p.m. Pacific Time, Monday through Friday, e-mail address [email protected]. For the Notice to U.S. Customers: If you are not able to have the defect remedied without charge and within a reasonable time, you may wish to submit a complaint to the Administrator, National Highway Traffic Safety Administration, 1200 New Jersey Avenue, SE., Washington, DC 20590; or call the Vehicle Safety Hotline at (888) 327-4236 (TTY: 800-424-9153); or to http://www.safercar.gov. For the Notice to Canadian Customers: If you wish to submit a complaint about this recall, you can contact Transport Canada road safety, 80 rue Noel, Gatineau, Quebec J8Z 0A1 or call (800) 333-0510. We regret any inconvenience this action may cause but feel certain you understand our interest in motor vehicle safety. WARRANTY CAMPAIGNS DEPARTMENT Enclosure Daimler Truck North America LLC Recall Campaign May 2022 FL921A NHTSA #22V-153 Page 4 Reimbursement to Customers for Repairs Performed Prior to Recall If you have already paid to have this recall condition corrected you may be eligible to receive reimbursement. Requests for reimbursement may include parts and labor. Reimbursement may be limited to the amount the repair would have cost if completed by an authorized Daimler Truck North America LLC dealer. The following documentation must be presented to your dealer for consideration for reimbursement. Please provide original or clear copies of all receipts, invoices, and repair orders that show: • The name and address of the person who paid for the repair • The Vehicle Identification Number (VIN) of the vehicle that was repaired • What problem occurred, what repair was done, when the repair was done • Who repaired the vehicle • The total cost of the repair expense that is being claimed • Proof of payment for the repair (such as the front and back of a cancelled check or a credit card receipt) Reimbursement will be made by check from your Daimler Truck North America LLC dealer. Please speak with your Daimler Truck North America LLC authorized dealer concerning this matter. Daimler Truck North America LLC Recall Campaign May 2022 FL921A NHTSA #22V-153 Page 5 Work Instructions Subject: Thomas Built Buses EFX Seat Bolts Models Affected: Specific model years 2020-2023 Thomas Built Saf-T-Liner EFX school buses manufactured June 6, 2019, through November 30, 2021. 1. Place the vehicle on a lift, but do not raise the vehicle at this time. 2. Turn the main power disconnect switch to the OFF position, then remove the negative battery cable. 3. Raise the vehicle to a comfortable working height, as shown in Fig. 1, to access the body clips. 04/19/2022 f910839 Fig. 1, Raised Vehicle Daimler Truck North America LLC Recall Campaign May 2022 FL921A NHTSA #22V-153 Page 6 04/19/2022 f910840 Fig. 2, Body Mounting Clip 04/19/2022 f910841 Fig. 3, Body Mounting Clip Removal Daimler Truck North America LLC Recall Campaign May 2022 FL921A NHTSA #22V-153 Page 7 4. Starting from the rear bumper, remove the two rear shear bolts, and the body mounting clips till approxi- s mately two window sections in front of the rear axle. See Fig. 2 and Fig. 3. The number of body mounting clips may vary depending on the vehicles option content, and length. 04/19/2022 f910842 Fig. 4, Supporting the Bus Body Daimler Truck North America LLC Recall Campaign May 2022 FL921A NHTSA #22V-153 Page 8 5. Using two jack stands and heavy gage square stock tubing, support the bus body on the left-hand side and the right-hand side behind the rear axle, as shown in Fig. 4. 6. With the body now supported, gently lower the chassis to gain approximately 4 to 6 inches of clearance between the top of the rear bumper and the body, as shown in Fig. 5. 04/19/2022 f910843 A A. Maintain a clearance of 4 to 6 inches between the bumper and the body. Fig. 5, Gap Between the Bumper and the Body 04/20/2022 f910844 1 C B A 10.00 B C A 10.00 10.00 91.00 The short end of the stepped shim is towards the front of the vehicle, and the thickest area is under the seat bolt. 1. Seat Bolt Location Fig. 6, Stepped Shim Daimler Truck North America LLC Recall Campaign May 2022 FL921A NHTSA #22V-153 Page 9 7. The shim is stepped with one side flat from end to end as, shown in Fig. 6 and Fig. 7. Make sure the shim is installed with the flat side down on the frame, as shown in Fig. 8. 04/19/2022 f910846 Fig. 7, Shim, Black Powder Coated Daimler Truck North America LLC Recall Campaign May 2022 FL921A NHTSA #22V-153 Page 10 NOTICE 04/20/2022 f910849 1 2 3 A A. Install the shim with the flat side down on the frame. 1. Stepped Shim 2. Front J-Hook 3. Rear J-Hook Fig. 8, Shim Installed on the Left-Hand Side Frame Rail On vehicles where AC hoses, harnesses, and power cables are encountered, secure these components so that no chafing occurs or they are not in close proximity to heat. Do NOT pull wires tight at connectors. For instructions, see service bulletin 00-8, Routing and Clipping Tips for Extending School Bus Life. IMPORTANT: The proper location of a shim is with its short end toward the front of the vehicle, and its center directly under the seat bolt, as shown in Fig. 9. This is the thickest area of the shim, providing the maximum clearance between the frame and the seat bolt. 8. Install one shim on the top of each frame rail flange as follows: 8.1 Pass the shim (short end first) through the top of the wheel well opening, as shown in Fig. 10. Daimler Truck North America LLC Recall Campaign May 2022 FL921A NHTSA #22V-153 Page 11 04/20/2022 f910848 A A. Seat Bolt Interference Point Fig. 9, Center of the Shim Located Under the Seat Bolt 04/19/2022 f910847 Fig. 10, Inserting the Shim Through Top of the Wheel Well Opening 8.2 Manipulate, and place the shim on top of the frame rail flange, with the shim sandwiched between the body crossmembers. 9. Repeat step 8 on the other side of the vehicle. Daimler Truck North America LLC Recall Campaign May 2022 FL921A NHTSA #22V-153 Page 12 10. Install the front and rear J-hook brackets. Make sure the top brackets are seated on top of the ends of the shim, as shown in Fig. 11 and Fig. 8. IMPORTANT: If necessary, reposition the J-hooks or shim to fully capture the end of the shim under the J-hook bracket. 11. Install the J-hooks. Tighten each J-hook nut until the top and bottom bracket deforms approximately 1/8 to 1/4 inch, as shown in Fig. 12, then stop tightening the nut. 04/19/2022 f910850 Fig. 11, J-Hook Installation 04/19/2022 f910851 1 A A. Tighten the nut clockwise until the flat bracket ends deform approximately 1/8 to 1/4 inch. 1. Shim Fig. 12, Front J-Hook Assembled View Daimler Truck North America LLC Recall Campaign May 2022 FL921A NHTSA #22V-153 Page 13 IMPORTANT: If a frame liner is installed in the area where a J-hook bracket is to be mounted, use a wide opening J-hook bracket TBB 235162, as shown in Fig. 13. 12. Raise the chassis in small increments while aligning the bus body to the frame so the body mounting clips and the rearmost body-to-chassis mounting bolts (shear bolts) can be installed. 04/25/2022 f910855 1 2 3 4 1. Body Shim 2. J-Hook Bracket 3. Frame 4. Frame Liner Fig. 13, Usage of Wide Opening J-Hook Bracket Daimler Truck North America LLC Recall Campaign May 2022 FL921A NHTSA #22V-153 Page 14 13. Install all the body mounting clips and rear shear bolts, as shown in Fig. 14 and Fig. 15. Tighten the body mounting clip nuts 30 lbf·ft (41 N·m). 04/19/2022 f910852 1 1. Frame Rail Fig. 14, Typical Body Mounting Clip Installation 04/19/2022 f910853 Fig. 15, Behind Rear Bumper View Daimler Truck North America LLC Recall Campaign May 2022 FL921A NHTSA #22V-153 Page 15 14. After the body is secured to the chassis, inspect the seat bolt for clearance, as shown in Fig. 16. 15. Remove the jack stands, then lower the vehicle. 16. Install the negative battery cable, then turn the main power disconnect switch to the ON position. 04/19/2022 f910854 Fig. 16, Clearance Between the Seat Bolt and the Body Secured to the Chassis

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 22V-153 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : Daimler Trucks North America, LLC Submission Date : MAR 11, 2022 NHTSA Recall No. : 22V-153 Manufacturer Recall No. : FL-921 Manufacturer Information : Manufacturer Name : Daimler Trucks North America, LLC Address : 4747 N. Channel Avenue Portland OR 97217-3849 Company phone : 800-745-8000 Population : Number of potentially involved : 539 Estimated percentage with defect : 75 % Vehicle Information : Vehicle 1 : 2020-2023 Thomas Built Buses Saf-T-Liner EFX School Bus Vehicle Type : BUSES, MEDIUM & HEAVY VEHICLES Body Style : Power Train : NR Descriptive Information : Saf-T-Liner EFX school buses with a potential interference of certain chassis cross-member bolts and certain passenger seat floor mounting bolts Production Dates : JUN 06, 2019 – NOV 30, 2021 VIN Range 1 : Begin : NR End : NR Not sequential Description of Noncompliance : Description of the Noncompliance : On the affected EFX school busesthere may be certain passenger seats that have a mounting bolt that may contact a chassis cross-member bolt. Over time, the passenger seat bolt may fatigue from vibration and side loading. A broken seat mounting bolt may impact the ability of the seat to meet the seat and belt requirements of FMVSS 210 and/or FMVSS 222. FMVSS 1 : NR FMVSS 2 : NR Description of the Safety Risk : A broken seat bolt may impact the ability of the seat to meet the requirements of FMVSS 210 and or FMVSS 222. This may increase the risk of injury to the occupants in the event of a crash. Description of the Cause : NR Part 573 Safety Recall Report 22V-153 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 Identification of Any Warning that can Occur : NR Involved Components : Component Name 1 : Fastener Component Description : BOLT HEX FLANGE 7/16-14X2.0 SAE GRADE 8 Component Part Number : 170727 Supplier Identification : Component Manufacturer Name : NR Address : NR NR Country : NR Chronology : In January 2022 DTNA received report from a customer of broken passenger seat floor mounting bolts. Thomas Built Buses (TBB) immediately initiated aquality containment on all EFX buses with similar configurations and began an investigation to determine the scope and potential consequences of the issue. TBB promptly began inspecting EFX buses on property and identified a certain cross-member location that may , under certain conditions of tolerance stackup, lead to interference between a seat mounting bolt and a cross-member bolt. TBB then promptly developed a predictive model, and validated it with inspection of EFX buses on property,that could compare seat and cross-member locations to identify suspect buses. At the same time, TBB reviewed FMVSS compliance testing data to determine if a broken bolt could affect the compliance of the seats. In March 2022 as soon as DTNA had sufficient information from its investigation, DTNA decided to conduct a voluntary non-compliance and safety recall on certain EFX school buses with a configuration that may allow a passenger seat mounting bolt and a chassis cross member bolt align and make contact. Part 573 Safety Recall Report 22V-153 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 Description of Remedy : Description of Remedy Program : Spacer will be added between the frame rails and body floor in the affected area on the affected buses to provide proper clearance between the passenger seat mounting bolt and a chassis cross member bolt. Repairs will be performed by Daimler Truck North America authorized service facilities.Details of the reimbursement plan will be included in the owner’s notification letter. How Remedy Component Differs from Recalled Component : NR Identify How/When Recall Condition was Corrected in Production : NR Recall Schedule : Description of Recall Schedule : Customer notification will be made by first class mail using Daimler Truck North America records to determine the customers affected. Planned Dealer Notification Date : MAY 09, 2022 – MAY 09, 2022 Planned Owner Notification Date : MAY 09, 2022 – MAY 09, 2022 * NR – Not Reported

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